Massoli v. Regan Media, et al Doc.

86

1 James L. Blair, #016125

Roger W. Hall, #013727
2 RENAUD COOK DRURY MESAROS, PA
Phelps Dodge Tower
3 One North Central, Suite 900
Phoenix, Arizona 85004-4417
4 (602) 307-9900
jblair@rcdmlaw.com
5 rhall@rcdmlaw.com
Attorneys for Plaintiff/Counterdefendants
6
UNITED STATES DISTRICT COURT
7
DISTRICT OF ARIZONA
8
JENNA MASSOLI p/k/a JENNA JAMESON,
9 CV 05-0854 PHX EHC
Plaintiff,
10
v. ATTORNEY’S CERTIFICATE OF
11 COMPLIANCE WITH
“REGAN MEDIA,” JUDITH REGAN, as an LRCiv 83.3(b)(2)(A)
12 individual,

13 Defendant.
REGAN MEDIA, INC., a New York corporation, (Assigned to the Honorable
14 and JUDITH REGAN, an individual, Earl H. Carroll)
15 Defendants/Counterclaimants,
16 v.
17 JENNA MASSOLI, p/k/a JENNA JAMESON, an
individual,
18
Plaintiff/Counterdefendant,
19
and
20
JAY GRDINA, an individual,
21
Third-Party Counterdefendant,
22
and
23
DOLCE AMORE, INC., a Colorado corporation,
24
Counterdefendant.
25

26
LAW OFFICES

RENAUD COOK
DRURY MESAROS
ONE NORTH CENTRAL
SUITE 900
PHOENIX, AZ 85004
TELEPHONE 602-307-9900
FACSIMILE 602-307-5853
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Case 2:05-cv-00854-EHC Document 86 Filed 03/07/2006 Page 1 of 4
Dockets.Justia.com
 1 Pursuant to LRCiv 83.3(b)(2)(A), Rules of Practice of the United States District Court

2 for the District of Arizona, attorney Roger W. Hall of the firm of Renaud Cook Drury

3 Mesaros, PA (“RCDM” or the “firm”) hereby certifies that on June 24, 2005, attorney Gary

4 Crandell, Esq., of Denver, Colorado, longtime transactional counsel for

5 plaintiff/counterdefendants Jenna Massoli p/k/a Jenna Jameson, Jay Grdina, and Dolce Amore,

6 Inc. was notified, by an e-mail from the undersigned, of this Court’s June 20 pretrial order. A

7 copy of the pretrial order was attached to that e-mail.

8 On November 28, 2005, Counterdefendant Jay Grdina, husband of plaintiff Jenna

9 Massoli and one of two sole shareholders of Dolce Amore, Inc. (along with Massoli), was

10 notified, by e-mail from the undersigned, of the pretrial order. A copy of the pretrial order

11 was attached to Mr. Grdina’s e-mail.

12 On February 15, 2006, the undersigned e-mailed Mr. Grdina and attorney Crandell a

13 copy of a letter the undersigned had received from opposing counsel. Opposing counsel

14 advised that another motion to compel, as well as a motion for sanctions would be

15 forthcoming unless the responses to their Request for Production of Documents was

16 supplemented to be responsive. Again, the undersigned requested contact from Mr. Grdina.

17 On February 20, 2006, the undersigned e-mailed attorney Gary Crandell, Esq., of

18 Denver, Colorado, Massoli and Grdina’s longtime transactional counsel, with copies of

19 Defendants/Counterclaimants’ most recent filings in this matter, i.e., the Second Motion to

20 Compel and Request for Sanctions, etc. On February 21, 2006, copies were sent to

21 Mr. Grdina as well.

22 On March 1, 2006, attorney Jim Blair of this office sent a letter to Mr. Grdina,

23 Ms. Jameson, and attorney Crandell, via e-mail and U.S. mail, setting forth certain

24 requirements that would need to be complied with on or before March 3, 2006, and advising

25 that if those requirements were not met, that the firm would be forced to withdraw from

26 representation.
LAW OFFICES

RENAUD COOK
DRURY MESAROS
ONE NORTH CENTRAL
SUITE 900
PHOENIX, AZ 85004
TELEPHONE 602-307-9900
FACSIMILE 602-307-5853
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Case 2:05-cv-00854-EHC Document 86 Filed 03/07/2006 Page 2 of 4
 1 Neither Mr. Grdina, Ms. Jameson, nor Mr. Crandell responded to that letter, either by

2 reply e-mail, or by telephone.

3 On March 7, 2006, Mr. Grdina and attorney Crandell were reminded, via e-mail, of the

4 pending response deadline regarding Defendants/Counterclaimants’ Second Motion to

5 Compel and Motion for Sanctions, etc. On that same date, Mr. Grdina was also furnished with

6 additional copies of those papers.

7 On March 7, 2006, the undersigned advised opposing counsel that RCDM would be

8 withdrawing from its representation of Plaintiff/Counterdefendants and sought an extension of

9 time for RCDM’s clients to file a response to the Second Motion to Compel and Motion for

10 Sanctions. Opposing counsel refused to grant an extension, and Mr. Grdina and attorney

11 Crandell were advised of that fact.

12 Mr. Grdina has been fully apprised of all pending dates and deadlines in this matter.

13 RESPECTFULLY SUBMITTED this 7th day of March, 2006.

14 RENAUD COOK DRURY MESAROS, PA

15

16 By: /s/ Roger W. Hall

James L. Blair
17 Roger W. Hall
Phelps Dodge Tower
18 One North Central, Suite 900
Phoenix, AZ 85004-4417
19 Attorneys for Plaintiff/Counterdefendants

20

21 Filed electronically this

7th day of March, 2006.
22
COPY of the foregoing hand-delivered
23 to the Honorable Earl H. Carroll the 8th day
of March, 2006.
24

25 ///

26 ///
LAW OFFICES

RENAUD COOK
DRURY MESAROS
ONE NORTH CENTRAL
SUITE 900
PHOENIX, AZ 85004
TELEPHONE 602-307-9900
FACSIMILE 602-307-5853
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Case 2:05-cv-00854-EHC Document 86 Filed 03/07/2006 Page 3 of 4
 1 COPY of the foregoing mailed this 7th day
of March, 2006, to:
2
Jeffrey F. Reina, Esq.
3 LIPSITZ, GREEN, FAHRINGER, ROLL,
SALISBURY & CAMBRIA LLP
4 42 Delaware Avenue, Suite 300
Buffalo, NY 14202-3857
5 Co-counsel for Plaintiff/Counterdefendants

6 David J. Bodney, Esq.

Dennis K. Blackhurst, Esq.
7 STEPTOE & JOHNSON, LLP
Collier Center
8 201 East Washington Street, Ste 1600
Phoenix, AZ 85004-2382
9 Attorneys for Defendants/Counterclaimants

10 Ms. Jenna Massoli

16444 North 91st Street, Suite 100
11 Scottsdale, Arizona 85260

12 Mr. Jay Grdina

16444 North 91st Street, Suite 100
13 Scottsdale, Arizona 85260

14 Dolce Amore, Inc.

c/o Mr. Jay Grdina
15 16444 North 91st Street, Suite 100
Scottsdale, Arizona 85260
16
Dolce Amore, Inc.
17 15720 N. 83rd Place
Scottsdale, Arizona 85260
18

19
/s/ Deborah Robertson
20
@PFDesktop\::ODMA/MHODMA/IMANAGE;RCD_PHX;319559;1
21

22

23

24

25

26
LAW OFFICES

RENAUD COOK
DRURY MESAROS
ONE NORTH CENTRAL
SUITE 900
PHOENIX, AZ 85004
TELEPHONE 602-307-9900
FACSIMILE 602-307-5853
(Page 4) @PFDesktop\::ODMA/MHODMA/IMANAGE;RCD_PHX;319559;1
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